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The assessee in its various grounds of appeal has challenged the order of the Ld. CIT(A) in confirming the addition of Rs. 4,25,810/- and has also challenged the validity of proceedings u/s. 147.

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Section 147&148 of the Income Tax Act, 1961 — Reassessment — Principal Commissioner while giving approval had simply mentioned "satisfied", similarly, the additional Commissioner had simply mentioned yes, it was a fit case to issue notice under section 148. since, both the approving authorities had given the approval in a mechanical manner, the reassessment proceedings were not in accordance with law — Mukesh Chand Garg vs. Income tax Officer [2019] 76 ITR (trib) 344 (Delhi)

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